all events test


all events test
For accrual method taxpayers, income is earned when:
(1) all the events have occurred which fix the right to receive the income and
(2) the amount can be determined with reasonable accuracy. Accrual of income cannot be postponed simply because a portion of the income may have to be returned in a subsequent period.
Under this test an accrual basis taxpayer may deduct taxes or any other expense items if all the events fixing the fact of, and amount of, taxpayer's liability have transpired though not paid, and this requires that each taxable year must be treated as a separate unit, and all items of gross income and deductions must be reflected in terms of their posture at close of such year. Dravo Corp. v. U.S., 348 F.2d 542, 545, 172 Ct.Cl. 200

Black's law dictionary. . 1990.

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